The Central Government has issued two separate notifications granting income-tax exemption to statutory development authorities under the provisions of the Income-tax Act, 1961, in order to provide clarity and certainty regarding the tax treatment of their specified income.
In exercise of the powers conferred under clause (46) and clause (46A) of section 10 of the Income-tax Act, 1961, the exemptions have been notified by the Central Board of Direct Taxes (CBDT).
New Okhla Industrial Development Authority (NOIDA)
Under Notification No. 171/2025, dated 15 December 2025, the Central Government has notified New Okhla Industrial Development Authority (NOIDA), an authority constituted by the State Government of Uttar Pradesh, for exemption in respect of its specified income under section 10(46) of the Income-tax Act, 1961.
The exemption covers specified income including grants received from the State Government, receipts from disposal and renting of land and buildings, interest and dividend income, and fees, tolls and charges collected under the Uttar Pradesh Industrial Area Development Act, 1976.
The notification is subject to conditions, inter alia, that NOIDA shall not engage in any commercial activity, the nature of activities and specified income shall remain unchanged, and income-tax returns shall be filed in accordance with the provisions of the Act.
The exemption shall be deemed to apply for Assessment Years 2012–13 to 2015–16, corresponding to Financial Years 2011–12 to 2014–15, and has been issued in compliance with the directions of the Hon’ble Delhi High Court.
Punjab Urban Planning and Development Authority (PUDA)
Further, under Notification No. 172/2025 [S.O. 5778(E)], dated 15 December 2025, the Central Government has notified Punjab Urban Planning and Development Authority (PUDA), an authority constituted under the Punjab Regional and Town Planning and Development Act, 1995, for the purposes of exemption under section 10(46A) of the Income-tax Act, 1961.
The notification shall be effective from Assessment Year 2024–25, subject to the condition that PUDA continues to function as an authority constituted under the said State Act with one or more of the specified purposes laid down in the Income-tax Act.
These notifications aim to ensure tax certainty for statutory development authorities engaged in planned urban and industrial development activities in accordance with their respective State legislations.
The Notifications can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2025/12/CBDT-NN-171-172.pdf
